- 1. How do I find the correct approved packaging?
- 2. UN-Marking of dangerous goods packagings: A selection criterion?
1. How do I find the correct approved packaging?
Step 1 - Determine the classification of the dangerous substance or dangerous object that is to be carried, the aim being to establish:
- the "correct" UN number
- the "correct" packaging group
- the "correct" physical state
- the "correct" vapour pressure level.
- Go to the alphabetic index of substances and articles, Table B in Chapter 3.2 of the RID or the Annex of the RSE in the index of the IMDG Code, and search for the name of the corresponding dangerous substance;
- if you do not find the name of the substance, go to BAM's GEFAHRGUT database (Quick Info), for example, or the BAM List, to see whether the substance has been assigned to a collective group;
- if this attempt also proves unsuccessful, perform the classification in compliance with Part 2 of the Dangerous Goods Regulations. Do not rely on classification information found on old safety data sheets! Information that may have been correct years ago, may now be wrong because the respective regulations have changed.
Step 2 - Determine the transport requirements for the dangerous substance or dangerous object that is to be carried.
- Go to Table A of Chapter 3.2 of the ADR/RID, or to the Dangerous Goods List in Chapter 3.2 of the IMDG Code, column 1, and look for the UN number determined in step 1; Remark: The ICAO-TI and the IATA Dangerous Goods Regulations for air transport are still arranged alphabetically
- if the table shows more than one entry (line) for this UN number, use the packaging group, the physical state and the vapour pressure as a basis for determining the applicable entry (line) of this UN number;
- This line shows coded information concerning all transport regulations concerning the use of enclosures relevant to this particular dangerous substance (labels, special requirements, limited quantities, packaging instructions and special packaging instructions);
- in the introduction to Chapter 3.2 as well as in the table heading, there is information for each column describing where - i.e. which chapter or subchapter - explains how to resolve this coded information;
- in each case you must also carefully note the corresponding general regulations (for example, see Section 4.1.1).
Step 3 - Go to the corresponding chapter of Part 6 of the regulations and determine the minimum requirements with regard to the construction, equipment, approval, testing and labelling of the dangerous goods enclosure to be used for the respective dangerous substance, and also determine the individual additional requirements that apply for the specific individual application.
- Dangerous objects, e.g. aerosol cans or airbags are not considered as inner receptacles with dangerous content; they are the actual dangerous goods themselves. Packagings and large packagings can only be used for this purpose if and when they have passed the type test in conjunction with these objects or the corresponding non-dangerous dummies. The UN coding of the approved packaging does not reveal this property.
- Even where regulations formally leave a choice between different types of packaging, such freedom of choice only appears to exist where explosive substances or explosive objects (including Class 9 airbag modules!), Class 4.1 self-decomposing substances and Class 5.2 organic peroxides are concerned, because the tests for determining the classification (= danger) has been performed in certain packagings. Changing this packaging could invalidate the classification (e.g. increased confinement effect).
- Single packagings and IBCs for liquid substances can be recognized by their UN coding. From these designations you can generally derive the maximum permissible densities and vapour pressures of the liquids, but not the maximum effective internal pressures and the stacking loads.
- Packagings with an "S" in the UN code do not reveal whether they have been approved as single packagings for solid bulk goods or as a combination packaging (exceptions: sacks, combination packagings and IBCs are only permitted as single packagings).
- If the type tests for packagings with an "S" in the UN code were performed with solid bulk goods, it must be examined whether the bulk goods for which they are intended are comparable to the test bulk goods with respect to bulk density, angle of repose and grain size.
- If the type tests and approvals for packagings with an "S" in the UN code were performed with inner receptacles as combination packagings, it must be examined whether the inner receptacles for which they are intended are comparable to the actual application with respect to the contents (solid or liquid), material, form, size and coding (see special case combination packaging).
2. UN-Marking of dangerous goods packagings: A selection criterion?
In order to guard against misunderstandings: No, it doesn’t!
The approval is the permission to produce and label from an assembly line a packaging that is to be used for the carriage of dangerous goods; it is not an approval for the use of such goods:
(ADR/RID Chapter 6.1.3 Marking)
The marking indicates, that the packaging which bears it corresponds to a successfully tested design type, and that it complies with the requirements of this Chapter related to the manufacture, but not to the use of the packaging. In itself, therefore, the mark does not necessarily confirm that the packaging may be used for ANY substance: generally the type of packaging (e.g. steel drum), its maximum capacity and/or mass, and any special requirements are specified for each substance in Table A of Chapter 3.2.
Although these explanations can formally only be found for packagings within the narrower sense, they also apply analogously for IBCs and for large packagings, because the same principle of UN coding is to be applied there as for packagings. The first sentence of Note 3 is also worth repeating here again:
The marking does not always provide full details of the test levels, etc., and these may need to be taken further into account, e.g. by reference to a test certificate, to test reports or to a register of successfully tested packagings.
This makes it completely clear that, to meet one's responsibility in this respect, it is not adequate to simply use an authorized packaging bearing a corresponding UN marking without applying more detailed information. This could lead to a totally unacceptable result with respect to the application of the respective packaging.
If all of the relevant information about the test level or detailed test conditions for the packaging or the IBC are present in the above stated sense, the potential user will err nonetheless if he thinks that he has then complied with all of his obligations under the dangerous goods regulations.
The user must know that a packaging may be only meeting the minimum requirements necessary for obtaining an approval for application. Chapter 4.1 of the RID/ADR titled "Use of packagings, including intermediate bulk containers (IBCs) and large packagings" begins with the following ominous requirement:
188.8.131.52 Dangerous goods shall be packed in good quality packagings, including IBCs and large packagings which shall be strong enough to withstand the shocks and loadings normally encountered during carriage, including trans-shipment between transport units and between transport units and warehouses as well as any removal from a pallet or overpack for subsequent manual or mechanical handling.
Packagings, including IBCs and large packagings, shall be constructed and closed so as to prevent any loss of contents when prepared for transport which might be caused under normal conditions of transport, by vibration, or by changes in temperature, humidity or pressure (resulting from altitude, for example). No dangerous residue shall adhere to the outside of packagings, IBCs and large packagings during carriage. These provisions apply, as appropriate, to new, reused, reconditioned or remanufactured packagings and to new, reused, repaired or remanufactured IBCs, and to new or reused large packagings.
Since there is no definition of what worldwide normal conditions of carriage are, the user is obliged to specify a design of packaging that meets the requirements of his particular application, since only he knows whether the packaging will be going on a long sea voyage into hot and moist tropical climates, or by rail into cold Siberia.
Furthermore, the user should know that during shipment by air there will be a drop in air pressure. Thus, even in the case where the approval does not require an inner receptacle in a combination packaging, the user must have provided evidence that a test for 75 kPa or 95 kPa respectively has been successfully passed.
The crucial point remains, that the packaging or the IBC must be designed in such a way that the charge does not escape under normal conditions of carriage, whereby it is clear that aspects such as vibrations, changes in temperature, changes in humidity or pressure play no role whatsoever for the issuance of the approval. In fact, for boxes made of carton exactly the opposite is prescribed: To ensure environmentally uniform test conditions, these packagings are not to be drop tested or stack tested under the real humidity conditions that are to be expected; instead these tests are to be performed under prescribed normal climatic conditions.